Crown CollegeHigher Education

National Student Loan Data System (NSLDS) Enrollment Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2023 through June 30, 2024 Type of Finding: * Significant Deficiency in Internal Control Over Compliance * Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. Condition: During our testing, we noted four of the 40 student's enrollment date per NSLDS did not match the school's effective date per their records. Furthermore, one out of 40 student's program enrollment effective date did not match their enrollment effective date. Questioned Costs: None. Context: During our testing, it was noted the College does not have a process in place to ensure timeliness and accuracy of NSLDS reporting. Cause: The College did not have a process in place to ensure the student who withdrew were reported timely and accurately. Effect: The College did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely and accurately. Repeat Finding: No. Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials: There is no disagreement with the audit finding.

2022-001 Higher Education Emergency Relief Funds (HEERF) Procurement, Suspension and Debarment Federal Agency: U.S. Department of Education Federal Program Title: HEERF Assistance Listing Number: 84.425 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: - Significant Deficiency in Internal Control Over Compliance - Other Matters Criteria or Specific Requirement: Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations requires Colleges to have a written procurement policy that includes certain requirements as it relates to procuring goods and services using federal dollars. Additionally, 2 CFR 180.995 requires that the College has a written policy where Colleges should perform a check to ensure vendors are not debarred. Condition: During our testing, it was noted that the College did not have a procurement policy that contained certain required elements nor did they perform all the required procurement procedures related to the HEERF expenditures. Also, it was noted during testing that there is no written policy that requires the College to verify that vendors are suspended or debarred nor did they perform any procedures related to the HEERF expenditures on such vendors. Questioned Costs: None Context: The College did not have appropriate documentation that met the procurement, and suspension and debarment federal requirements. Furthermore, they did not have written policies in place at time of procurement or entering into contracts with vendors that aligned with the uniform guidance. Cause: The College was unaware of this federal requirement since it is their first federal grant that was non-student financial aid. Effect: All requirements were met, but it is also required that the policies be documented in a written form. Without written policies it is likely that required steps in the process may be missed. Repeat Finding: No Recommendation: We recommend that the College review their Procurement and Suspension and debarment policies and ensure that any missing federal requirements are included in their written policies. Views of responsible officials: There is no disagreement with the audit finding.

2021-001 Higher Education Emergency Relief Funds (HEERF) Reporting Federal Agency: U.S. Department of Education Federal Program Title: HEERF Assistance Listing Number: 84.425 Award Period: July 1, 2020 to June 30, 2021 Type of Finding: - Significant Deficiency in Internal Control Over Compliance - Other Matters Criteria or Specific Requirement: Per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the Institution?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Institutions were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. Condition: During our testing of the reporting process, we noted: 1. The College was unable to provide the 45 Day Report and September 30, 2020, student quarterly report. 2. The December 31, 2020 and March 30, 2021, student and institutional quarterly report was not updated as they had no expenditures during such periods. Based on the guidance, institutions are required to upload reports for each quarter even if the total are zero or unchanged unless the report was indicated as "FINAL" thus all expenditures (HEERF I-III) had been spent. Questioned Costs: None Context: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed. Cause: The College did not have someone tracking the requirements to ensure that they posted the reporting timely and accurately. Effect: There was inaccurate reporting on the College?s website. Repeat Finding: No Recommendation: We recommend the College establish a system to track due dates of reports to ensure timely submission. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program: Title: Student Financial Assistance Cluster CFDA Numbers: 84.038 ? Federal Perkins Loans Award Period: July 1, 2019 to June 30, 2020 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: The Code of Federal Regulation, 34 CFR 674.43 requires a servicer to send a first overdue notice within 15 days after the due date of the payment if the servicer has not received a payment, a request for deferment or a request for postponement or for cancellation. Further, a servicer shall send a second overdue notice within 30 days after the first overdue notice is sent and a final demand letter within 15 days after the second overdue notice. This letter must inform the borrower that unless the institution receives a payment or a request for deferment, postponement, or cancellation within 30 days of the date of the letter, it will refer the account for collection or litigation, and will report the default to a credit bureau. Condition: The College utilizes University Accounting Service, LLC (UAS) for its third-party Perkins Loan servicing. This is a very common practice for colleges and universities in order to provide the most efficient and effective means to not only collect loans but meet the federal regulations for servicing student Perkins Loans. In auditing the compliance features for the loan servicing, CliftonLarsonAllen utilizes the external compliance report performed for UAS by other auditors. We noted within the UAS compliance audit report for the year ended June 30, 2020, there was a finding for not contacting the student within the required timeframes. The audit did not specify the students that were not contacted within the required guidelines and UAS is one of the largest third-party servicer for federal student loans. Therefore, we do not know if there were any Crown College students that were impacted by the noncompliance noted at UAS. Questioned Costs: None Context: We noted the College?s third-party servicer compliance audit noted that of the fifty students tested, two students were sent past due notices late and one student was not sent the proper past due notices. Cause: UAS, the third-party servicer, did not have controls in place to ensure they complied with Department of Education Rules and Regulations in regards to timely engagement with students with federal loans. Given Crown College relies on UAS to meet their compliance responsibilities and there was not testing completed specifically for Crown College to determine if the noncompliance is specific to them, this is a finding for the College. Effect: UAS is not in compliance with all statutory or regulatory provisions as it pertains to the notification of students exiting its grace period. Any finding UAS receives that is not mitigated with additional testing (with results of no errors specific to the college or university), that finding becomes a finding of the institutions they service. Repeat Finding: No Recommendation: We recommend that the College implement a thorough review process of all third-party servicer contracts to make sure they comply with all Department of Education Rules and Regulations. View of Responsible Official: There is no disagreement with the audit finding.

Grace Period Notification Federal Agency: Department of Education Federal Program: Title: Student Financial Assistance Cluster CFDA Numbers: 84.038 Award Criteria or Specific Requirement: Type of Finding: Significant Deficiency in Internal Control over Compliance Period: July1, 2018 to June 30, 2019 The Code of Federal Regulation, 34 CFR 674.42 requires contact to a borrower for the first time 90 days after the commencement of any grace period. The College at this time shall remind the borrower of his or her responsibility to comply with the terms of the loan. The College is then required at 150 days and 240 days to send subsequent notices to notify the borrower of the first required payment. Condition: The College utilizes University Accounting Service, LLC (UAS) for its third-party Perkins Loan servicing. This is a very common practice for colleges and universities in order to provide the most efficient and effective means to not only collect loans but meet the federal regulations for servicing student Perkins Loans. In auditing the compliance features for the loan servicing, CliftonLarsonAllen utilizes the external compliance report performed for UAS by other auditors. We noted within the UAS compliance audit report for the year ended June 30, 2019, there was a finding for not contacting the student within the required timeframes. The audit did not specify the students that were not contacted within the required guidelines and UAS is one of the largest third-party servicer for federal student loans. Therefore, we do not know if there were any Crown College students that were impacted by the noncompliance noted at UAS. Questioned Costs: None. Context: We noted the College?s third-party servicer, UAS, failed to comply with notifying students of their grace period as required noting 2 of 50 students were noncompliant. Cause: UAS, the third-party servicer, did not have controls in place to ensure they complied with Department of Education Rules and Regulations in regards to timely engagement with students with federal loans. Given Crown College relies on UAS to meet their compliance responsibilities and there was not testing completed specifically for Crown College to determine if the noncompliance is specific to them, this is a finding for the College. Effect: UAS is not in compliance with all statutory or regulatory provisions as it pertains to the notification of students exiting its grace period. Any finding UAS receives that is not mitigated with additional testing (with results of no errors specific to the college or university), that finding becomes a finding of the institutions they service. Repeat Finding: No. Recommendation: We recommend that the College implement a thorough review process of all third-party servicer contracts to make sure they comply with all Department of Education Rules and Regulations. View of Responsible Official: There is no disagreement with the audit finding.

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION